The 90-day window: What happens to beneficiaries whose coverage was terminated by the state's troubled Medicaid verification system | Arkansas Blog

The 90-day window: What happens to beneficiaries whose coverage was terminated by the state's troubled Medicaid verification system

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Around 47,000 Medicaid beneficiaries in the state have had their coverage terminated or are set to lose coverage at the end of this month — not because they were ineligible, but because they did not respond to a letter requesting additional income verification quickly enough (the state has imposed a 10-day deadline for response). Or they tried to respond but DHS could not process it in time and their coverage was auto-terminated. Many or most of those impacted are likely Medicaid eligible according to the income data that triggered the letters in the first place.

What happens to those folks now? In the case of people who have actually transitioned out of the program, most have options to sign up now for heavily subsidized health insurance on the Arkansas Health Insurance Marketplace. Unfortunately, however, there is no strong system in place to assist them and inform them about options if they are terminated via the 10-day letter. 

As for those who are in fact eligible, the good news is that they have options guaranteed by federal law to re-enroll without having to start over entirely with a new application. The governor has referred to this as an "appeal," but he misspoke in characterizing it this way. An appeal would be a more complicated process if DHS found the beneficiary ineligible and the beneficiary wanted to contest that finding. That's not what's happening here. Federal regulations demand that anyone whose coverage is terminated for failure to submit verification information gets 90 days to submit the necessary information and be re-enrolled if eligible, without having to re-apply. The regs demand this happen "in a timely manner," and DHS Director John Selig told me that despite the hiccups in the system so far, beneficiaries responding in the 90-day window would be processed promptly (DHS caseworkers may need to do followup with some). DHS officials have also stated that beneficiaries who had their coverage interrupted would be covered retroactively by fee-for-service Medicaid. 

If beneficiaries had their coverage terminated and believe they are still eligible, they should submit the information requested by DHS on the original income-verification letter (see here for examples of proof of income — employed beneficiaries need to provide multiple pay stubs from the previous month, a letter form an employer, or other proof; self-employed beneficiaries need to provide a tax return; unemployed beneficiaries need to provide a signed letter explaining they they have no income).  DHS officials suggested that beneficiaries in this situation go to the county office in person or mail it in to the location listed on the notice.

It is worth noting that 90 days is the minimum required by the feds; Arkansas could choose to give folks longer. Given the mess so far, that might be an option worth considering, but let's not hold our breath.



Hopefully, most eligible beneficiaries who have been kicked off of their insurance will get back on over the next three months. There will undoubtedly be some people lost in the shuffle even with this 90-day window. Everyone understands that many of these beneficiaries can be difficult to track down. Efforts to do outreach and communicate with them about what's going on have clearly been inadequate. Some have moved, and some may not even realize that their coverage has been terminated. 
 
One open question as beneficiaries re-enroll is how quickly they will be able to get back onto the particular plan they had via the private option. It's a little bit more complicated in Arkansas than it is in traditional Medicaid states to turn the enrollment faucet off and back on again. Beneficiaries who re-enroll during the 90-day window will initially be put into traditional Medicaid. Selig told me that they would then be placed back into their old private plan within a month or two; currently this is a manual process and eventually they are hoping to have an automated, streamlined process in place. Worth noting, as we've mentioned elsewhere,  that the private option is really supposed to reduce problems with "churn" (folks moving on and off different coverage plans). Will be interesting to watch how this process goes.  

Of course, all of the above assumes that DHS will be able to promptly, smoothly, and efficiently process beneficiaries who attempt to re-enroll in the 90-day window. Obviously the last few weeks don't exactly inspire confidence. There is no state outreach program in place to communicate with folks and explain their options at this point, but hopefully community organizations, insurance companies, and brokers can help to pick up some of the slack. Make no mistake, even if they re-enroll in the 90-day window, the terminations represent disruptive hassle for beneficiaries and a break in coverage that could threaten access to care. Not to mention additional bureaucratic burden for the state. If eligible beneficiaries miss the 90-day window, they would still be able to re-enroll but would have to start over with a new application (so hassle, disruption, delays, etc. would be even worse) and they wouldn't have the same protection of retroactive coverage. 

Under the circumstances, it's unfortunate that DHS was unable to get more replies in the first place. Perhaps they might have had more luck giving beneficiaries more time to respond (as required by federal law for annual renewals) and developing a more extensive effort to communicate with beneficiaries, involving various stakeholders in a process that would have taken more than 10 days. Well, we'll never know. 

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